TaxTMI 
TaxTMI 
2025 (6) TMI 707
X X X X Extracts X X X X
X X X X Extracts X X X X
....t, 1961 [hereinafter referred to as 'the Act']. 2. The brief facts of the case are that the original return of income was filed by the assessee on 11.11.2017 declaring total income of Rs. 3,03,880/-. The return was duly processed under Section 143(1) of the Act. The case was selected for complete scrutiny under CASS. Notice under Section 143(2) of the Act was issued through ITBA on 21.09.2018 which was served upon the assessee electronically. Further notice was also served upon the assessee on 25.09.2019 by Speed Post. Thereafter, notice under section 142(1) of the Act was also issued alongwith questionnaire on 23.05.2019, 04.07.2019, 22.07.2019 & 05.08.2019 through ITBA calling information which was also served upon the assessee electroni....
X X X X Extracts X X X X
X X X X Extracts X X X X
....p duty i.e. the investment made in immovable property was also treated by the Assessing Officer as unexplained and added back to the total income of the assessee under Section 69A of the Act which is to be taxed under Section 115BBE of the Act. Penalty under Section 271AAC of the Act was initiated on the addition of Rs. 17,58,219/-. 3. Aggrieved with the Assessment Order of the Assessing Officer, the assessee had filed an appeal before the First Appellate Authority which was decided by the impugned order and the appeal of the assessee was dismissed, as no compliance was made by the assessee before the ld. CIT(A) as well. The assessee is now in second appeal before us. 4. The following grounds have been taken by the assessee in its appeal:....
X X X X Extracts X X X X
X X X X Extracts X X X X
....he assessee had not made any compliance in the course of appeal proceeding. He submitted that the issues were not examined on merits as per the mandate of Section 250(6) of the Act. The Ld. Sr. Counsel requested that the matter may be set aside to the file of the Ld. CIT(A) for fresh adjudication of the appeal of the assessee on merits in accordance with law. The Ld. Sr. Counsel further submitted that the assessee will co-operate with the Ld. CIT(A) and furnish all necessary details and explanations as called for by the CIT(A) in the set aside appellate proceeding. 6. Per contra, Shri Ashok Kumar Suthar Ld. Sr. DR submitted that the assessee had neither appeared before the Assessing Officer nor before the Ld. CIT(A) and no compliance was m....